ISSN 2369-2391
Memorandum D17-2-4
Ottawa, January 26, 2017
Preparation and Presentation of Blanket B2 Adjustment
Requests
In Brief
This memorandum contains the procedures and instructions surrounding the preparation and presentation of
Blanket B2 Adjustment Requests.
Corrections were made to the definitions of Blanket B2 Adjustment, Issue, and Reason. Paragraph 4 was also
amended for clarification purposes.
Disclaimer: The company names and addresses are purely fictional for the purposes of outlining exactly how
the information should be presented and formatted in Form B2. Any similarities presented in all examples in
D17-2-4, to current or past importer or brokers, are by coincidence only.
TABLE OF CONTENTS
LEGISLATION
DEFINITIONS
GUIDELINES AND GENERAL INFORMATION
SPECIAL IMPORT MEASURES ACT
BLANKET B2 AUTHORIZATION APPLICATION
BLANKET B2 ADJUSTMENT REQUEST SUBMISSION
BLANKET ADJUSTMENTS SUBMITTED AS A RESULT OF A CBSA TRADE VERIFICATION
INTEREST
ADDITIONAL INFORMATION
APPENDIX A - BLANKET B2 AUTHORIZATION APPLICATION
APPENDIX B – SAMPLE FORM B2
APPENDIX C - BLANKET B2 WORKSHEET TEMPLATE
APPENDIX D - ESTABLISHING THE INTEREST MEDIAN DATE
APPENDIX E - ADDRESSES OF CBSA REGIONAL TRADE OFFICES THAT ACCEPT BLANKET B2
AUTHORIZATION APPLICATIONS
REFERENCES
LEGISLATION
Customs Act
Special Import Measures Act
Memorandum D17-2-4
January 26, 2017
2
DEFINITIONS
For the purpose of this memorandum, the following definitions apply:
“Act” means the Customs Act.
Form B3, Canada Customs Coding Form
Referred to as a B3-3 (the electronic fillable version of the form) in many of the Canada Border Services
Agency’s (CBSA) electronic documents. It is the customs document used to account for imported commercial
goods. It is still called B3, as it will be referred to throughout this memorandum.
Form B2, Canada Customs – Adjustment Request
Referred to as Form B2. It is the CBSA’s document used to request an adjustment to a commercial accounting
declaration.
Blanket B2 adjustment
Is an adjustment that corrects accounting information pertaining to one issue and up to three reasons, each
having 25 or more B3 transactions.
Blanket B2 Authorization Application
Is an application package submitted to the CBSA by an importer/agent, requesting authorization to submit a
Blanket B2 Adjustment Request. It consists of an application form, workbook(s) containing data on all
transactions for which adjustments are being requested, and an Agency Agreement if applicable.
Blanket B2 Adjustment Request
Is comprised of a Form B2 and the workbook(s) containing data on all of the transactions for which
adjustments are being requested. It is submitted by an importer/agent after receiving a letter of authorization
from the CBSA.
Diversion
Occurs when the conditions for which an imported good was granted relief of duty are no longer met (see
Memorandum D11-8-5, Conditional Relief Tariff Item).
F Type Transaction
Is a consolidated transaction used to account for goods released under the Courier Low Value Shipment (LVS)
Program.
Issue
Is the legislative authority associated with the adjustment request (e.g., 74(1) (c.1) or 32.2(2) of the Act).
Reason
Is the description of the circumstances for which a correction is being requested (e.g., correction of origin,
tariff classification, value for duty).
Workbook
Is an electronic file containing multiple worksheet pages within a spreadsheet application.
Worksheet
Is a page or sheet within a workbook.
Memorandum D17-2-4
January 26, 2017
3
GUIDELINES AND GENERAL INFORMATION
1. This memorandum is intended for the use of importers/agents who prepare and submit blanket B2
adjustments to the CBSA.
2. Blanket B2 adjustments are used to correct the same issue for up to three reasons affecting multiple B3
transactions with a single request rather than submitting individual B2 claims for each transaction. They are
designed to reduce the administrative burden for importers/agents and the CBSA.
3. A submission is considered a blanket B2 adjustment when there are a total of 25 or more transactions, in a
12 month period, that require correction for the same reason. Adjustment requests containing 24 or fewer
transactions will not be considered a blanket adjustment and should be submitted as single B2 adjustment
requests. Refer to Memorandum D17-2-1, The Coding, Submission and Processing of Form B2 Canada
Customs Adjustment Request for further information on single B2 adjustments.
4. A Blanket B2 Authorization Application may be submitted to correct one issue containing up to three
reasons; however, the CBSA reserves the right to accept or reject any or all of the reasons for which a
correction is being requested. Each reason for which a blanket B2 adjustment is being requested must be
presented as an individual workbook in the application package.
5. This memorandum provides the standardized format for preparing Blanket B2 Adjustment Requests.
Individual trade programs may, however, have additional requirements that must be included in the Blanket B2
Adjustment Request (e.g., Special Import Measures Act (SIMA) Compliance, Compliance Verification, Origin
or Valuation).
6. The submission of a blanket B2 adjustment does not remove an importer’s obligation under section 32.2 of
the Act to voluntarily amend their original declarations within 90 days of having “reason to believe” that their
declaration of tariff classification, origin or value for duty of the goods was incorrect. For more information
regarding “reason to believe” and the obligation to self-adjust please refer to Memorandum D11-6-6, “Reason
to Believe” and Self-adjustments to Declarations of Origin, Tariff Classification, and Value for Duty.
7. Instances where a blanket B2 adjustment request cannot be used include:
(a) classifications subject to Tariff Rate Quotas;
(b) cases where licenses are applicable;
(c) overages (should be reported on a voluntary entry);
(d) Courier Low Value Shipment consolidated transaction (F-type entries);
(e) requests for further re-determination (sections 60 or 61 of the Act);
(f) appeals (sections 67 and 68 of the Act); or,
(g) requests relating to accounting documents for which the time limit for appeal, refund or diversion
has expired.
8. “F” type transactions must be submitted separately on single B2 adjustment requests under the guidelines
related to the Courier Low Value Shipment (LVS) transaction process. Please refer to Memorandum D17-4-0,
Courier Low Value Shipment Program.
Memorandum D17-2-4
January 26, 2017
4
SPECIAL IMPORT MEASURES ACT
9. Adjustment requests related to issues under SIMA cannot be combined with other legislative issues on a
Blanket B2 Adjustment Request. Furthermore, Blanket B2 Adjustment Requests related to SIMA require that
written pre-approval be obtained from the SIMA Compliance Unit Manager. All requests related to SIMA are
to be sent directly to:
Canada Border Services Agency
Trade and Anti-dumping Programs Directorate
222 Queen Street, 9th floor
Ottawa, Ontario, K1A 0L8
Attention: Manager, SIMA Compliance Unit
10. Additional information regarding requests under SIMA legislation is contained in Memorandum D14-1-3,
Re-determinations and Appeals Under the Special Import Measures Act.
BLANKET B2 AUTHORIZATION APPLICATION
11. Importers/agents must obtain authorization from the CBSA regional trade office, closest to where their
books and records are maintained, before submitting a Blanket B2 Adjustment Request (refer to Appendix E
for a list of CBSA offices that accept Blanket B2 Authorization Applications). To obtain authorization, a hard
copy of the Blanket Authorization Application (see Appendix A) must be submitted along with:
(a) an Agency Agreement where applicable; and,
(b) an electronic workbook(s) (CD-R media) containing data on all of the transactions for which
adjustments are being requested, in chronological order by accounting date (see example of required
format in Appendix C).
12. The completed workbook(s) must be saved to a CD-R disk media only. The CD-R media must be clearly
labelled as a Blanket B2 Authorization Application and include the importer’s name, business number, and
adjustment period (ex: Blanket B2 Authorization Application - ABC Company, 123456789RM0001, January
2011 – January 2015). Submission of Blanket B2 Authorization Applications will not be accepted via
electronic mail (e-mail) or any other electronic media.
13. The workbook must be saved under the importer’s name or business number and include the adjustment
period (Example: ABC Company, 2011-2015 or 123456789RM0001, 2011-2015).
14. Supporting documentation is not required when submitting the Blanket B2 Authorization Application;
however, the adjustment reason(s) for the blanket request must be clearly explained.
15. Blanket B2 Authorization Applications must be approved by the CBSA before Form B2s can be submitted.
Therefore, Form B2s submitted along with the Blanket B2 Authorization Application will not be accepted.
16. The filing of a Blanket B2 Authorization Application does not constitute filing an adjustment request
pursuant to section 32.2 or 74 of the Act. It in no way removes or extends the time limits to file a required
adjustment pursuant to section 32.2 of the Act nor does it extend the one year (under 74 (1)) C.1)) or the four
year time limits to file a refund request pursuant to section 74 of the Act. Importers/agents should submit
individual B2 adjustment requests for transactions that are approaching their legislative time limits.
Memorandum D17-2-4
January 26, 2017
5
17. The CBSA will conduct a review of the Blanket B2 Authorization Application and will notify the
importer/agent in writing of its status. Supporting documentation will be requested, when necessary.
18. Where supporting documentation is requested, the importer/agent will receive specific written instructions
from the CBSA on the documentation required. Not adhering to these instructions may result in the request
being rejected.
19. The CBSA will issue a blanket B2 adjustment authorization letter, for applications that have been reviewed
and accepted.
BLANKET B2 ADJUSTMENT REQUEST SUBMISSION
20. Once an importer/agent receives an authorization letter, they may submit a Blanket B2 Adjustment
Request. When submitting a Blanket B2 Adjustment Request, the following documentation should be
included:
(a) two copies of the completed Form B2 (see Appendix B for example); one for the CBSA and one for
the importer/agent receipt copy;
(b) electronic workbook(s) saved on CD-R disk media and in the format specified in paragraphs 22-25 of
this memorandum; and,
(c) a hard copy of the electronic workbook(s).
21. The following fields of the Form B2 must be completed:
(a)
(b)
(c)
(d)
(e)
(f)
the Header (Fields 1, 2, 4, 10 and11);
Fields 5, 6 and 7 should indicate “VAR” (various);
Explanation;
Declaration;
Justification for Request; and,
the Trailer (Fields 38-45);
22. If the Blanket B2 Adjustment Request contains transactions with accounting dates that cover more than
one calendar year, then separate Form B2s and their associated workbooks will be required for each calendar
year. Each workbook must include worksheets that separate the B2 adjustments by calendar quarter.
23. The worksheet for each quarter must contain the accounting data originally submitted on the B3, and the
requested changes (i.e., B2 data). Each worksheet must be prepared in chronological order according to the
accounting date.
24. The completed workbooks should be saved to CD-R disk media only. The CD-R disk media must be
clearly labelled as a Blanket B2 Adjustment Request and include the importer’s name, business number,
adjustment period, and authorization number provided on the CBSA’s letter of authorization (Example:
Blanket Request - ABC Company, 123456789RM0001, January 2011 – January 2015, Authorization #
XXXXX).
25. Each workbook must be saved under the importer’s name or business number and include the year
(Example: ABC Company, 2011 or 123456789RM0001, 2011). Each worksheet, within the workbook, must
be named under the importer’s name or business number and include the quarter period (Example: ABC
Company Q1-2011, ABC Company Q2-2011 etc. or 123456789RM0001 Q1-2011, 123456789RM0001 Q22011). Either format is acceptable but must be consistent for all files.
Memorandum D17-2-4
January 26, 2017
6
26. When submitting blanket B2 adjustments that contain split line changes, the split line methodology, as per
D17-2-1, must be used. Responsibility rests with the importer/agent to correctly number the new line resulting
from the split or the sub header, when a new sub header is required.
27. When the Blanket B2 Adjustment Request results in monies owing to the CBSA (i.e., accounts receivable),
payment may be submitted with the request. All requests submitted with payments should be sent to the closest
CBSA Cash Office along with an envelope, addressed to the authorizing office or the CBSA officer who
conducted the verification, if the request is a result of a verification. Non-revenue and/or accounts payable
Blanket B2 Adjustment Requests should be submitted to the CBSA regional trade office that authorized the
blanket request or to the CBSA officer that conducted the verification (see Appendix E for a list of CBSA
offices). Importers/agents may also submit non-revenue and/or accounts payable Blanket B2 Adjustment
Requests to their closest CBSA office, for forwarding to the appropriate CBSA regional trade services office.
BLANKET ADJUSTMENT SUBMITTED AS A RESULT OF A CBSA
TRADE VERIFICATION
28. Pursuant to a CBSA trade compliance verification, an importer may be required to submit corrections
within 90 days from the date of the final verification report. These corrections may be submitted as a Blanket
B2 Adjustment Request.
29. A Blanket B2 Authorization Application is not required for Blanket B2 Adjustment Requests submitted as
a result of a CBSA trade compliance verification, provided that all the adjustment requests fall within the
scope of the verification and the reassessment period. Adjustment requests outside of the verification scope or
period must be submitted as single B2 adjustment requests or as a standard Blanket B2 Adjustment Request,
requiring a Blanket B2 Authorization Application.
30. B2 Blanket Adjustment Requests must be directed to the officer who conducted the verification and should
include:
(a) an Agency Agreement where applicable;
(b) Form B2 referencing the verification case number and completed as per paragraph 21 of this
memorandum;
(c) electronic workbook(s) saved on CD-R disk media in the format specified in paragraphs 22-25 of this
memorandum (Note: the verification case number should be referenced instead of an authorization
number); and,
(d) a hard copy of the electronic workbook(s).
INTEREST
31. When calculating interest, the median date will be considered as the date the interest begins. The median
date equals the date between the first and last transaction within the respective quarter (see Appendix D for
example). When the number of days in a period is an even number, the date immediately after the median date
will be used. For blanket B2 adjustments that are submitted without payment, interest will continue to
accumulate until the Detailed Adjustment Statement (DAS) decision date.
Memorandum D17-2-4
January 26, 2017
7
32. As indicated in paragraph 27, importers/agents may choose to submit the payment with their Blanket B2
Adjustment Request, if applicable. Should they choose to do so; the importer/agent is responsible for
calculating interest. The interest start date should be calculated as per the calendar quarter median method
described above in paragraph 31 and the end date should be the date payment is presented.
33. For further information on the application of interest, refer to Memorandum D11-6-5, Interest and Penalty
Provisions: Determinations/Re-determinations, Appraisals/Re-appraisals, and Duty Relief.
ADDITIONAL INFORMATION
34. For more information, from within Canada, you may call the Border Information Service at 1-800-4619999. From outside Canada you may call 204-983-3500 or 506-636-5064. Long distance charges will apply.
Agents are available Monday to Friday (08:00 – 16:00 local time / except holidays). TTY is also available
within Canada: 1-866-335-3237.
Memorandum D17-2-4
January 26, 2017
8
APPENDIX A – BLANKET B2 AUTHORIZATION APPLICATION
Part 1 – Applicant Identification
Business Name (legal)
Business Number (BN)
RM Extension
Preferred Language of Correspondence (English or French)
Business Address (Street No.; P.O. Box and/or RR No.)
City
Province
Country
Broker/Service Provider Name
Postal Code
Agency Agreement/Third Party Consent attached?
Business Address (Street No.; P.O. Box and/or RR No.)
City
Province
Contact Name
Telephone Number
Country
Postal Code
Title
Fax Number
E-mail address
Detail of correction(s) (attach letter if space is insufficient).
Adjustment Reason(s) and Legislative Authority (ies). If filed under Sect. 32.2 of the Customs Act, include date of Reason to Believe
Note that the filing of a Blanket B2 Authorization Application does not constitute filing an adjustment request pursuant to
section 32.2 or 74 of the Act. It in no way removes or extends the time limits to file a required adjustment pursuant to section
32.2 of the Act, nor does it extend the one year (section74(1)(c.1) of the Act ) or the four year time limits to file a refund request
pursuant to section 74 of the Act.
Part 2 – Workbook and Supporting Documentation
Provide a workbook of all the transactions related to the adjustment request in electronic and hard copy format.
Additional supporting documentation may be required, depending on the nature of the claim.
In the case of an application being filed by an agent on behalf of an importer, also include the Agency Agreement / power
of attorney
Documents in support of the adjustment(s) may include, but are not limited to:
i.
ruling(s) or other CBSA direction;
ii.
descriptive literature;
iii.
example(s) of typical entries with supporting documentation;
iv.
Certificate(s) of Origin;
Memorandum D17-2-4
January 26, 2017
9
proof of diversion to qualified end-use or end-user; and,
financial records.
v.
vi.
Description: This image is of a sample Blanket B2 Authorization. Part 1- Applicant Identification is a form
with the following fields:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Business Name (legal)
Business Number (BN)
RM Extension
Preferred language of correspondence (i.e. English, French)
Business Address (street No. P.O. Box and/or RR No.)
City
Province
Country
Postal Code
Contact Name
Title
Telephone Number
Fax Number
Email Address
Details of correction(s). Attach letter if space is insufficient
Adjustment Reason(s) and Legislative Authority(ies). If filed under Section 32.2 of the Act, Include
date of Reason to Believe.
Memorandum D17-2-4
January 26, 2017
10
APPENDIX B – SAMPLE FORM B2
Description:
This image is of a sample Form B2 completed for a blanket request. The Header is filled out with the
Company Name (field 1), Business Number and Transaction Number (field 2). The Page (field 4), the Address
(field 10), the Security Number (field 11) as well as the Trailer is filled out with Customs Duties (field 38),
GST (field 42), Interest (field 43) and Amount Due Receiver General (field 44). Fields 5, 6 and 7 all indicate
“various”. A justification and explanation is provided. All the fields in the declaration box are filled out.
Memorandum D17-2-4
January 26, 2017
11
APPENDIX C - BLANKET B2 WORKSHEET TEMPLATE
This worksheet template must be used when preparing and submitting a Blanket B2 Authorization Application and
a Blanket B2 Adjustment Request.
Memorandum D17-2-4
January 26, 2017
12
Description:
This image displays a Blanket B2 Worksheet Template. Under the “As Accounted for” header, the following rows
are listed: Company Name, Reason for Adjustment, and Business Number. The following columns are then listed:
B3 Transaction Number, Accounting Date, Office, Sub-Header Number, Country of Origin, Country of Export,
Tariff Treatment, Direct Shipment date, Currency Code, Vendor, Line Number, Description, Classification
number, Quantity, Unit of Measure, Value for Duty Code, Custom Duty Rate, Value for Currency Conversion,
Value for Duty, Custom Duty, Value for Tax and GST. Under the “As Claimed” header”, the following columns
are listed: Sub-header Number, Country of Origin, Country of export, Tariff Treatment, Direct Shipment Date,
Currency Code, Line Number/ Split Line Indicator, Description, Classification, Quantity, Unit of Measure, Value
for Duty Code, Special Import Measures Act Code, Rate of Duty, Value for Currency Conversion, Value for Duty,
Duty, Value for Tax, and GST. Under the “Identify if amount is due to Receiver General or Client” header, the
following columns are listed: GST Due to Receiver General or Client and Duty due to Receiver General or Client.
Sample data has been provided for 3 fictional entries.
Memorandum D17-2-4
January 26, 2017
13
APPENDIX D - ESTABLISHING THE INTEREST MEDIAN DATE
2015
January
February
March
Su Mo Tu We Th Fr Sa
Su Mo Tu We Th Fr Sa
Su Mo Tu We Th Fr Sa
4
5
6
7
1
2
3
1
2
3
4
5
6
7
1
2
3
4
5
6
7
8
9
10
8
9
10 11 12 13 14
8
9
10 11 12 13 14
11 12 13 14 15 16 17
15 16 17 18 19 20 21
15 16 17 18 19 20 21
18 19 20 21 22 23 24
22 23 24 25 26 27 28
22 23 24 25 26 27 28
25 26 27 28 29 30 31
29 30 31
Using the sample calendar quarter above, the following table demonstrates how to establish the median date within a calendar
quarter for the interest start date.
First Transaction Date
Last Transaction Date
Median Date
January 1, 2015
March 31, 2015
February 15, 2015
January 22, 2015
March 31, 2015
February 25, 2015
January 12, 2015
February 17, 2015
January 30, 2015
Regardless of the number of transactions in the calendar quarter, or if the majority of transactions occur in a particular month
of the calendar quarter, the date range is based on the median date between the first and last transaction dates.
The following formulas are to be used:
•
•
For a period containing an even number of days:
For a period containing an odd numbers of days:
(n ÷ 2) + 1
(n + 1) ÷ 2
Where “n” represents the total number of days between the first and the last transaction within the respective quarter.
Description:
This image displays the calendars for the months of January, February and March 2015.
Memorandum D17-2-4
January 26, 2017
14
APPENDIX E - ADDRESSES OF CBSA REGIONAL TRADE OFFICES THAT
ACCEPT BLANKET B2 AUTHORIZATION APPLICATIONS
Quebec / Atlantic Region
Canada Border Services Agency
Trade Operations Division
c/o B2 Processing Centre
400 Youville Square, 5th floor
Montreal, QC H2Y 2C2
Canada
Greater Toronto Area / Northern Ontario Region
Canada Border Services Agency
Trade Operations Division
c/o B2 Processing Centre
1980 Matheson Blvd. E., Suite 144
Mississauga, ON L4W 5R7
Prairie Region
Canada Border Services Agency
Trade Operations Division
Victory Building
269 Main Street
Winnipeg, MB R3C 1B3
Canada
Canada Border Services Agency
Trade Operations Division
2588 - 27th Street N.E.
Calgary, AB T1Y 7G1
Canada
Pacific Region
Canada Border Services Agency
Trade Compliance Division
412 - 4th Floor 1611 Main Street
Vancouver, BC V6A 2W5
Canada
Memorandum D17-2-4
January 26, 2017
15
References
Issuing Office
Trade and Anti-dumping Programs Directorate
Headquarters File
Legislative References
Customs Act
Special Import Measures Act
Other References
Form B2, Form B3, D11-6-5, D11-6-6, D11-8-5, D14-1-3,
D17-2-1, D17-4-0
Superseded Memorandum D
D17-2-4 dated January 17, 2017
Memorandum D17-2-4
January 26, 2017